Dan Schuyler, the senior director of exchange technology for Leavitt Partners, said in theory, the CMS is supposed to send a batch file of 2015 enrollees to each insurer; if an old enrollee does not appear in the new file, that customer's plan should be discontinued.
But an insurance company representative who did not want to be named said insurers would prefer the CMS to send an affirmative notification of members' termination to avoid any mix-ups.
The agency already sends out such termination notices in certain cases. A consumer who switches plans midyear by taking advantage of the change-of-circumstances and special enrollment provisions of the Patient Protection and Affordable Care Act triggers a termination transaction to the old plan. That leaves open the question as to why the agency cannot send such termination transactions to address insurer concerns. When asked, a CMS spokesman responded that the agency is “exploring the extent” to which they can send such transactions.
The CMS disputes that insurer concerns about duplicative enrollment and double-charging will occur. “CMS' top priority is that everyone who should be re-enrolled is re-enrolled,” he said. The agency has designed the re-enrollment process so that HealthCare.gov will send an enrollment transaction for everyone who should be re-enrolled, he said, “which means that issuers who do not receive a transaction for a member can safely let their policy end.”
Insurers also have other concerns. A HealthCare.gov website outage this past weekend alarmed Arches Chief Strategy Officer Ferris Taylor. The CMS took down the site for two groups—customers with special enrollment scenarios and insurers looking to test the next version of the website in the upcoming enrollment period. The purpose of the outage, a CMS spokesman said, was to support the “capacity readiness for the next open enrollment.”
The original plan, according to CMS e-mails, was to shutter the site on Sept. 6 at 3 a.m., and stretch that closure over the weekend. But in a series of seven e-mails, the time period of the outage was lengthened, with the end time shifting from Sept. 7 at 4:30 p.m. to 6:45 p.m. to 10:45 p.m. to 1:45 a.m. on Sept. 8. The site finally went back up later that morning.
The long and expanding downtime worried Taylor. It “tells me they're having technical problems,” he said. “This isn't going the way they planned.”
There's also a worry over the new enrollee login system. Exchange officials decided to scrap the old login system, called EIDM, and replace it with a new one. Observers hope the new login system will provide a smoother, more intuitive experience for consumers. Claire McAndrew, private insurance plan director for Families USA, a pro-Obamacare advocacy group, said the customer experience should be more “streamlined.”
But the replacement login system is in testing and won't be broadly available for testing by the insurance community until October. With open enrollment beginning Nov. 15, the tight timeline worries Taylor. “If there are glitches, there's not a cushion,” he said. “There's no time built in there.”
Observers are more sanguine regarding the new consumer-facing part of the system. Greene called the Accenture and Amazon Web Services combination the “A-team.” The hope is that Amazon's cloud services will be able to handle the millions of current exchange plan members seeking to re-enroll or shop around, the millions of new customers browsing for 2015 coverage.
Schuyler agreed that the customer experience should be better for 2015 than it was for 2014, arguing that the cloud technology “will make a difference.” But, he cautioned, the traffic may be so heavy that site performance still slows. However, he expects fewer glitches in the system than during the disastrous 2014 exchange rollout.
That opinion isn't unanimous. Brad Wilson, the president of Blue Cross and Blue Shield of North Carolina, said he remains wary about the effect of heavy website traffic. “The question we all have is, has there been simply enough time to build the capacity in a very complex technological environment to handle the volume. We'll see.”